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#2134695 - 06/16/17 07:06 PM Who do we CIP?
rrush Offline
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Joined: Dec 2011
Posts: 74
We are opening 1031 Exchange accounts. There is a Qualified Intermediary that is the only authorized person - for the actual owner of the funds, we have to have their SSN/TIN for tax reporting but they do not provide their CIP information since they have no access to the account. Do we really just have to CIP the Qualified Intermediary since they are the one that would be our customer?

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#2134703 - 06/16/17 07:33 PM Re: Who do we CIP? rrush
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
Yes, if the intermediary won't be doing the tax reporting, you will need the SSN/TIN for the owner of the funds. But your customer is the intermediary, and the CIP regulations say that is whom you CIP. Unless your bank's CIP expands that requirement to cover the third party in the arrangement, you don't CIP the owner of the funds.
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#2134715 - 06/16/17 07:47 PM Re: Who do we CIP? rrush
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
What he said.

You should require a W-9 or its equivalent executed by the owner if the account is interest bearing. Anything else is "bank policy."
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#2134726 - 06/16/17 08:23 PM Re: Who do we CIP? rrush
rrush Offline
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Joined: Dec 2011
Posts: 74
Thank you very much

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